Topic Bright

PRIVACY POLICY

Last Updated: November 09, 2023

Our Commitment to You

Digital Gardeners Holdings Inc. DBA Digifor are committed to safeguarding the use of your personal information that we have. Digital Gardeners Holdings Inc. DBA Digifor (referred to as "we", "our", and "us" throughout this notice) makes reasonable efforts to protect the security and confidentiality of the personal information we have and to ensure that such information is used for proper business purposes in connection with the management or servicing of your account. Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything we can to maintain that trust. Details of or approach to privacy and how your personal information is collected and used are set forth in this privacy policy.

This site privacy policy (“Privacy Policy”) explains how Digital Gardeners Holdings Inc. DBA Digifor collects, uses, shares, and safeguards information about you when you use the website Topic Bright and any associated content and materials available in connection with the website (collectively, the “Site”).

We reserve the right to make changes to this Privacy Policy at any time and for any reason. Any changes will be reflected in a revised policy posted on the Site and we will alert you that there has been a change by updating the “Revised” date displayed on the Privacy Policy. If Digital Gardeners Holdings Inc. DBA Digifor determines that such changes materially affect your privacy rights, we will provide additional notice to you.

Collecting Your Information. We may collect information about you in a variety of ways but generally speaking it is done either through you visiting our website. The types of information we may collect include, but are not limited to:

Information You Provide To Us.This is personal information you choose to provide in connection with you contacting us such as your name, phone number, address, or other activities in which you participate on the Site or services.

Information We Collect About You.Information our servers automatically collect when you visit, use, or browse the Site, such as your IP address, your operating system, browser version, the address of a referring website, the pages you visit on the Site, the dates and times you visit the Site, device and usage information, such as language preferences, referring URLs, country, location, information about how and when you use our services and other technical information. If you access the Site from a mobile device, information about the type of mobile device you use.

Additional Information. Digital Gardeners Holdings Inc. DBA Digifor does not collect any sensitive personal data on its users.

Using Your Information.Any information collected about you via the Site may be used to: help increase the efficiency and operation of the Site; deliver and improve our products and services; manage our business; monitor and analyze usage and trends to improve the Site and the user experience; send you confirmations, updates, alerts, administrative messages, and otherwise facilitate your use of the Site; request feedback and contact you about your use of the Site; respond to your emails; compile anonymous statistical information and analyses, which we may use internally and/or provide to third parties; to support our customers and their interactions with you through our Services; market our services to you that we believe may be of interest to you; and deliver information to you that you request or that we think may be of interest to you, such as articles, news, or information about various promotions.

Basis for Processing. Digital Gardeners Holdings Inc. DBA Digifor only processes your personal information when it has an appropriate basis. That means we determine whether we have a lawful basis/legitimate business purpose to use your personal information before doing so. As stated in applicable law, such lawful bases/legitimate business purposes include receiving express consent, operating our business, performing a contract, and complying with a legal obligation.

Legitimate Interest. When processing personal information based on Digital Gardeners Holdings Inc. DBA Digifor’s legitimate interest, Digital Gardeners Holdings Inc. DBA Digifor ensures that your fundamental rights and interests are not overridden. This is achieved through Digital Gardeners Holdings Inc. DBA Digifor's commitment to privacy by design principles, adherence to industry privacy standards, regular processing reviews, and a strong focus on the customer lifecycle. Digital Gardeners Holdings Inc. DBA Digifor relies on its legitimate interest for processing when it handles transaction processing, security, user analytics, and technical maintenance.

Contractual Performance. Digital Gardeners Holdings Inc. DBA Digifor processes your personal data when necessary for the performance of a contract when fulfilling our duties and exercising our rights under contracts with you, vendors, and partners. Additionally, when responding to consumer requests, and addressing customer service inquiries and requests for information.

Legal Obligation. Digital Gardeners Holdings Inc. DBA Digifor processes personal information to comply with any existing or future legal obligations including to detect and prevent unlawful acts, protect against malicious or illegal activity, and to provide assistance to law enforcement agencies.

Consent. Digital Gardeners Holdings Inc. DBA Digifor relies on your express consent, which you may withdraw, to process your personal data for servicing your registered account, promotions, and tailored marketing activities. These include facilitating and servicing your account to our mailing list and services, being attributed revenue for providing personalized promotions and special offers, and delivering marketing content that is tailored to your interests.

Sharing Your Information. We may share your information with third parties that perform services for or on our behalf this includes: (A) to perform analytics on website and/or web form engagement, (B) when it is shared as part of a transfer of assets, (C) for security and fraud purposes, and (D) when we are required by law to share it.

Consent. Analytics. We may allow selected service providers or processors, such as tracking technology on the Site, which will enable them to collect information about how you use the Site over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, attribute revenue, and better understand your online activity.

Transfer of Assets. If we reorganize or otherwise transfer some or all of the Site or our assets to another organization (such as in the course of a merger, dissolution, or liquidation), your information may be shared with the transferee; however, we will ask the transferee to honor commitments we made in this Privacy Policy.

Security and Fraud. We allow third parties to receive personal information from our users to provide both security and fraud protection to Digital Gardeners Holdings Inc. DBA Digifor.

Required By Law. We may share your information as permitted or required by any applicable law in response to a subpoena or other legal process or as we deem necessary to investigate or remedy any actual or potential violation of our policies or to protect the rights, property, and safety of the Digital Gardeners Holdings Inc. DBA Digifor or others, as we deem appropriate.

Sale of Personal Data. Digital Gardeners Holdings Inc. DBA Digifor does not sell your data in exchange for monetary consideration.

How We Use Cookies. The Site may use cookies, web beacons, and other tracking technology, depending on the features offered. Tracking technology is useful for gathering information such as browser type and operating system, tracking the number of visitors to the Site, and understanding how visitors use the Site. Cookies can also help us customize the Site and improve your experience.

If you previously provided personally identifiable information to us, a unique identifier in the cookie may tie the information collected via the cookie to such information. Do Not Track (“DNT”) is a privacy preference that users can set to have their Internet browser automatically send a signal to our online and mobile resources to request we not track browsing activity across different sites. There is, however, currently no universal standard for sending and receiving DNT signals. As such, we cannot promise that we respond to all DNT signals, but do recognize and respond when required by applicable privacy laws, such as when HTTP header fields or Java objects are used. Most web browsers are set to accept cookies by default. You can usually choose to set your browser to disable or reject cookies. Be aware that disabling or rejecting cookies could affect the availability and functionality of the Site or certain portions of the Site. Also, please note that we may still use information we’ve collected from cookies prior to your disabling them; however, we will not collect any further information from the disabled cookies. We use cookies for the following purposes:

Security of Your Information.While we take reasonable steps to protect any personally identifiable information you choose to provide via the Site from unauthorized access, please be aware that, despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online can potentially be intercepted and used by unauthorized parties, so please keep this in mind when disclosing any personal or personally identifiable information via the Site. To help ensure security via the Internet, we recommend you keep your browser up to date with automatic security updates enabled.

Policy for Children. We do not use the Site to solicit information from or market to children under the age of 18. By using the Site, you represent that you are at least 18 years of age. We encourage parents and legal guardians to monitor their children’s internet usage and to instruct their children never to provide personal information through the Site or any other website without parental consent. If you believe a child has provided personal information to us via the Site, please contact us and we will use reasonable efforts to locate and delete the information.

Links to Other Websites and Third Party Practices. The Site may contain links to third party websites. It is our intent to provide links only to other quality websites. However, we have no control over these linked websites or, for that matter, any third parties. Any information collected by websites, other than the Site, is not covered by this Privacy Policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites that may be linked to or from the Site. We encourage you to read the provisions of privacy policies on other websites before providing them with your personal information.

Submitting Information From Outside The United States. We may disclose your personal data for the purposes described above to recipients (including our subsidiaries, service providers, and advisors) that are located in a country outside of the country from which it was original collected, including the United Kingdom and the United States. Not all countries have equivalent data protection laws. You hereby expressly consent to the transfer of your personal data to recipients that are located outside your home jurisdiction, including the United States. In addition, unless you give us your explicit consent to do so, we will not use your personal data for any purposes unrelated to the purposes we describe in this notice.

Exercise Your Privacy Rights. Digital Gardeners Holdings Inc. DBA Digifor takes privacy seriously. Where applicable, data subjects have certain rights which they can request for Digital Gardeners Holdings Inc. DBA Digifor to fulfill. These requests can be made by either the data subject or an authorized agent. These rights include:

In order to exercise any of the rights detailed above, please contact us at policy@topicbright.com. We will use your email as proof of verification unless otherwise prohibited. Exercising your rights under this section will not result in any discrimination by Digital Gardeners Holdings Inc. DBA Digifor. We will treat you the same as any other user. If you disagree or dispute a decision that has been made on the scope or application of the rights described in this clause, you may appeal this decision by contacting us at policy@topicbright.com.

We will respond to your request to exercise any of the above rights in writing (including via email), or orally if requested, as soon as practicable and in any event not more than within one month after receipt of your request. In exceptional cases, we may extend this period by up to two months and we will tell you why. If you would like to exercise any of these rights, please contact us using the contact details provided above.

You have the right to complain to your data protection authority about our collection and use of your personal data. Please contact your local data protection authority for more information. Contact information for data protection authorities can be found here.

Retention Period. Digital Gardeners Holdings Inc. DBA Digifor shall only store personal information for as long as it is required. This is determined by considering the purposes for which it was obtained in accordance with applicable laws. Our retention period is based on (1) the nature of our relationship with the data subject and (2) any legal obligations we are bound to fulfill.

Contact Us. If you have questions or comments about this Privacy Policy, please email us at policy@topicbright.com. If you prefer, you may also contact us via at: